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2012 (10) TMI 528 - AT - Income TaxReassessment - After completion of assessment u/s 143(3), a notice us/ 148 was issued reopening the assessment u/s 147 - claim u/s 80HHC - held that:- Re-opening has been made on the self same materials which are already available on record at the time of assessment u/s 143(3). Therefore, reopening of assessment made on the basis of very same material amounts to change of opinion. Further, the assessee has disclosed all material facts fully and truly, therefore reopening of assessment could not have been made beyond four years from the end of the assessment year in dispute i.e., 2004-05. - Decided in favor of assessee.
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